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#2050218 - 11/18/15 02:09 PM BSA/CIP
LauraC Offline
New Poster
Joined: May 2015
Posts: 17
New Jersey
If there is an address discrepancy in a loan file (drivers license has a different address from the subject property which is owner occupied) and the lender documents occupancy sufficiently through a letter of explanations, Fraud Guard, or other documentary items, is it required for the lender to also include a summary of how the issue was cleared if the documentation speaks for itself? Can anyone reference a regulation requiring, or not requiring this extra step?

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#2050224 - 11/18/15 02:32 PM Re: BSA/CIP LauraC
rlcarey Online
10K Club
Joined: Jul 2001
Posts: 78,649
Galveston, TX
31 CFR 1020.200(a):

(3) Recordkeeping. The CIP must include procedures for making and maintaining a record of all information obtained under the procedures implementing paragraph (a) of this section.

(i) Required records. At a minimum, the record must include:

(D) A description of the resolution of any substantive discrepancy discovered when verifying the identifying information obtained.

Whatever you feel meets this requirement is what you keep in the file.
The opinions expressed here should not be construed to be those of my employer:

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